The purpose of the EPA's Superfund List, or National Priorities List (NPL) is to provide the funding, resources and acknowledgement of hazardous environments with the eventual intent for remediation. Naturally, one would assume site prioritization rests in the severity of the hazardous environment and the number of people affected, and in what nature . Yet upon closer examination it becomes apparent other "techno-political" characteristics of the site gravely affect site placement on the NPL and the site's relative ranking. Some of those factors studied and proven to have statistical significance in NPL identification and remediation include: race, class, political influence, and the presence of a responsible third party (usually a corporate identity) to pay for the clean up.
"As of March 2003, there were 1,484 sites on the Superfund list, and over 6.5 million people living in census tracts with Superfund sites" ( Impact of 12898)
In the first 10 years of the program, the U.S. EPA discovered over 1,400 potential Superfund sites (sites that were discovered and met hazard requirements for listing) but deleted only 25 ( Impact of 12898)
If a responsible third party is identified there is a 131% increase of placement on the NPL Additionally....
For every ten points given to a site's HRS (hazardous rating) the chance of selection decreases by 22%!! Percentage Chart From this, one can suggest sites are placed for affordability of cleanup rather than the severity of toxicity hazardous nature of the site.
The percentage of sites cleaned using funds from PRPs is estimated as high as 70% (U.S. EPA 2000). Therefore, sites with PRPs may be easier to list because they may be perceived as not competing for the scarce cleanup resources provided by the Superfund.
a 10% higher minority population lowers the chance of a Superfund listing by 2%, whereas a 10% higher poverty rate lowers the chance of being listed by 13%. ( Impact of 12898)
O'Neil's report cites a 1997 study that questions the representational equity of the superfund listing. The study displayed both the wealthiest and poorest counties are not selected and came to the interesting conclusion: The Superfund is a dominantly a middle class, industrial employment program rather than an equivocal hazardous waste clean up program.
Brownfield Selection...Superfund alternative?
We can see the same trends from Superfund applied to Brownfields
(Nope...just another name for Superfund)
Signed in 2002 the Brownfield Act is locally driven "land recycling" —
The initiative is to transform once industrial and now abandoned sites into safe and valuable additions to the local community. Many consider the Brownfield program as an alternative to the inefficiencies surrounding the EPA superfund list. Yet taking a closer look into Brownfield site selection and actual remediation statistics reveals a very similar picture to the Superfund program.
A study analyzed Brownfield placement between 2002 and 2006 discovering a "Powerful institutional and partisan representation appear more likely to receive Brownfields Program support. Brownfield Distributive Politics Study
In examining the Brownfield Award program we can once again notice a complete disregard of Executive Order 12898 , which explicitly requires environmental justice for minorities and lower income families - those most affected from environmental hazardous situations and most in need for remediation.
Through this statistic we can see where EO 12898 should have increased the likelihood for Brownfield placement....yet it hasn't. "Applicant communities where nonwhites constitute more than 61 percent of the population.... had a nearly identical likelihood of winning awards as when all variables are set at their mean." Brownfield Distributive Politics Study
In fact, the opposite is happening. Where EO 12898 should be giving these communites a greater change for remediation somehow statistics show these communities are still vastly underrepresented..."26 percent or more of their residents in poverty have a notably lower probability of winning an award (26 percent likelihood vs. 33 percent likelihood when all independent variables are set at their mean values)" Brownfield Distributive Politics Study
Same is true for Race as is with Poverty....The Brownfield Act Study determined... "localities with significant concentrations of individuals below poverty and individuals not self-identifying as white appear significantly less likely to win anEPABrownfields Program award." Yet those communities are much more likely to apply for the program's support.
Higher income communities...."where the top decile of Property Taxes — communities where property taxes exceed $3 million/square mile — have a 35 percent likelihood of winning an award vs. 33 percent" Brownfield Distributive Politics Study
Political dominion helps as well the study identifies those communities of which "an applicant community is located in a state where one or both of its Senators sit on the Superfund Subcommittee, the community has a higher likelihood of winning an award." A45% greater chance!!!Brownfield Distributive Politics Study
Local Case - Fort Edward, NY
3rd party participation - the driving factor for site clean up...yet focused on economics NOT environment! The Hudson River dredging project is a current local superfund cleanup effort to dredge out PCBs from the Hudson. It is a case of Superfund clean-up with very high third party participation (General Electric). Yet through this case we can understand how third party participation can lead to clean up decisions benefiting cost interests rather than environmental or community interests. In this case the EPA was highly compliant to GE's requests to reduce the number of de-watering facilities (drastically reducing cost) and consequently drastically affecting the single de-watering facility site, Fort Edward, NY. Other proposed sites Moreau and Schaticoke were eliminated due to political (Moreau) and race/class (Schaticoke) attributes.
Through this case we can understand the involvement and interest of the third party acting against the best interests of the toxic clean up. Somehow, it is in the best interest for the health and safety of all communities involved to remove 2.65 million cubic yards of PCB-contaminated sediment (the largest dredging project in history) from just one single site. GE spokesman commented "We evaluated the characteristics of the two proposed locations (Bethlehem and Fort Edward) that have been identified by the EPA....We found that both sites are viable, but that the Fort Edward site is preferred." GE Wants One Site
The de-watering burden Fort Edward, NY must undertake includes 24 hours a day, six days a week mechanical clamshell removal. "Up to seven dredges could be operating at one time. A fleet of 12 or more barges will transport the contaminated muck, making up to 26 trips through Lock 7 to the dewatering facility each day." Dredging Scope
Local business in Fort Edward is completely destroyed...
The town's single tourist attraction, the Fort Edward Yacht Basin was closed eliminating the tourist season and town revenues entirely.
The town is predominately urban farmers who must now seek water supply alternatives for crops-- the clean Champlain Canal is now used as a PCB highway and unsuitable as a crop water supply.
Property values are significantly diminished. The people of Fort Edward are more or less trapped on their lands. They cannot sell and do not have the means to re-locate.
Alternative to EPA's Superfund and Brownfields... As an organization, I doubt the effectiveness of the EPA in creating any truly sustainable environmental impact. It may seem like a strong statement but the EPA has serious lack of funding and lack of environmental law enforcement issues that cripple the effectiveness of the organization. (Not to mention the strong governmental and therefore corporate ties). The step from Superfund listing to Brownfields is a progressive attempt forward because it encourages and exemplifies the need for local activism and participation. The Brownfield program was intended to empower local communities and governments to apply for monetary awards so they may avoid third party interactions and revitalize the property however the community best sees fit. However, it is still tied to the EPA and subject to the political factors involved in site selections creating a program less and less different from the Superfund.
A study evaluating the impact of the EPA's community involvement programs documents that the EPA's "fundamental principle is that people who live and work near a site should know what EPA is doing to clean it up, and should have input into the cleanup decision-making process." However through the Fort Edward cause we can understand that public participation is heard only when it wants to be. Community members are quoted saying the EPA and GE made up their minds about the dewatering site location long before distributing any information to the people of Fort Edwards.
That same study found that there are several reasons why community members do not choose to participate in the Superfund decisions two of those being the " feeling incapable of providing knowledgeable input, and the belief that the EPA will do what it wants regardless of community input." EPA Participation Study
I would suggest a program with the same initiatives as the Brownfield organization yet the program must be disassociated from the EPA and handled entirely through local governments and public movements. Local-ism has the potential to make a drastic impact because it are those government officials, small business owners, and residents who are most affected and most importantly understand the complete extent of the hazardous site. Clean up decisions would be centered around choosing the best methods generating the most effective clean up with the least adverse health and local economic impacts.
Clinton WJ. 1994. Executive Order 12898. Federal actions to address environmental justice in minority populations and low-income populations Fed Reg59:FR7629 http://www.hud.gov/offices/fheo/FHLaws/EXO12898.cfm
See Fort Edward case study below for additional description.
Superfund Selection
The purpose of the EPA's Superfund List, or National Priorities List (NPL) is to provide the funding, resources and acknowledgement of hazardous environments with the eventual intent for remediation. Naturally, one would assume site prioritization rests in the severity of the hazardous environment and the number of people affected, and in what nature . Yet upon closer examination it becomes apparent other "techno-political" characteristics of the site gravely affect site placement on the NPL and the site's relative ranking. Some of those factors studied and proven to have statistical significance in NPL identification and remediation include: race, class, political influence, and the presence of a responsible third party (usually a corporate identity) to pay for the clean up.
"As of March 2003, there were 1,484 sites on the Superfund list, and over 6.5 million people living in census tracts with Superfund sites" ( Impact of 12898)
In the first 10 years of the program, the U.S. EPA discovered over 1,400 potential Superfund sites (sites that were discovered and met hazard requirements for listing) but deleted only 25 ( Impact of 12898)
If a responsible third party is identified there is a 131% increase of placement on the NPL
Additionally....
For every ten points given to a site's HRS (hazardous rating) the chance of selection decreases by 22%!! Percentage Chart
From this, one can suggest sites are placed for affordability of cleanup rather than the severity of toxicity hazardous nature of the site.
The percentage of sites cleaned using funds from PRPs is estimated as high as 70% (U.S. EPA 2000). Therefore, sites with PRPs may be easier to list because they may be perceived as not competing for the scarce cleanup resources provided by the Superfund.
a 10% higher minority population lowers the chance of a Superfund listing by 2%, whereas a 10% higher poverty rate lowers the chance of being listed by 13%. ( Impact of 12898)
O'Neil's report cites a 1997 study that questions the representational equity of the superfund listing. The study displayed both the wealthiest and poorest counties are not selected and came to the interesting conclusion: The Superfund is a dominantly a middle class, industrial employment program rather than an equivocal hazardous waste clean up program.
Brownfield Selection...Superfund alternative?
We can see the same trends from Superfund applied to Brownfields
(Nope...just another name for Superfund)
Signed in 2002 the Brownfield Act is locally driven "land recycling" —
The initiative is to transform once industrial and now abandoned sites into safe and valuable additions to the local community. Many consider the Brownfield program as an alternative to the inefficiencies surrounding the EPA superfund list. Yet taking a closer look into Brownfield site selection and actual remediation statistics reveals a very similar picture to the Superfund program.
A study analyzed Brownfield placement between 2002 and 2006 discovering a "Powerful institutional and partisan representation appear more likely to receive Brownfields Program support. Brownfield Distributive Politics Study
In examining the Brownfield Award program we can once again notice a complete disregard of Executive Order 12898 , which explicitly requires environmental justice for minorities and lower income families - those most affected from environmental hazardous situations and most in need for remediation.
Through this statistic we can see where EO 12898 should have increased the likelihood for Brownfield placement....yet it hasn't. "Applicant communities where nonwhites constitute more than 61 percent of the population.... had a nearly identical likelihood of winning awards as when all variables are set at their mean." Brownfield Distributive Politics Study
In fact, the opposite is happening. Where EO 12898 should be giving these communites a greater change for remediation somehow statistics show these communities are still vastly underrepresented..."26 percent or more of their residents in poverty have a notably lower probability of winning an award (26 percent likelihood vs. 33 percent likelihood when all independent variables are set at their mean values)" Brownfield Distributive Politics Study
Same is true for Race as is with Poverty....The Brownfield Act Study determined... "localities with significant concentrations of individuals below poverty and individuals not self-identifying as white appear significantly less likely to win an EPA Brownfields Program award." Yet those communities are much more likely to apply for the program's support.
Higher income communities...."where the top decile of Property Taxes — communities where property taxes exceed $3 million/square mile — have a 35 percent likelihood of winning an award vs. 33 percent" Brownfield Distributive Politics Study
Political dominion helps as well the study identifies those communities of which "an applicant community is located in a state where one or both of its Senators sit on the Superfund Subcommittee, the community has a higher likelihood of winning an award." A 45% greater chance!!! Brownfield Distributive Politics Study
Local Case - Fort Edward, NY
3rd party participation - the driving factor for site clean up...yet focused on economics NOT environment!
The Hudson River dredging project is a current local superfund cleanup effort to dredge out PCBs from the Hudson. It is a case of Superfund clean-up with very high third party participation (General Electric). Yet through this case we can understand how third party participation can lead to clean up decisions benefiting cost interests rather than environmental or community interests. In this case the EPA was highly compliant to GE's requests to reduce the number of de-watering facilities (drastically reducing cost) and consequently drastically affecting the single de-watering facility site, Fort Edward, NY. Other proposed sites Moreau and Schaticoke were eliminated due to political (Moreau) and race/class (Schaticoke) attributes.
Through this case we can understand the involvement and interest of the third party acting against the best interests of the toxic clean up. Somehow, it is in the best interest for the health and safety of all communities involved to remove 2.65 million cubic yards of PCB-contaminated sediment (the largest dredging project in history) from just one single site. GE spokesman commented "We evaluated the characteristics of the two proposed locations (Bethlehem and Fort Edward) that have been identified by the EPA....We found that both sites are viable, but that the Fort Edward site is preferred." GE Wants One Site
The de-watering burden Fort Edward, NY must undertake includes 24 hours a day, six days a week mechanical clamshell removal. "Up to seven dredges could be operating at one time. A fleet of 12 or more barges will transport the contaminated muck, making up to 26 trips through Lock 7 to the dewatering facility each day." Dredging Scope
Local business in Fort Edward is completely destroyed...
The town's single tourist attraction, the Fort Edward Yacht Basin was closed eliminating the tourist season and town revenues entirely.
The town is predominately urban farmers who must now seek water supply alternatives for crops-- the clean Champlain Canal is now used as a PCB highway and unsuitable as a crop water supply.
Property values are significantly diminished. The people of Fort Edward are more or less trapped on their lands. They cannot sell and do not have the means to re-locate.
Alternative to EPA's Superfund and Brownfields...
As an organization, I doubt the effectiveness of the EPA in creating any truly sustainable environmental impact. It may seem like a strong statement but the EPA has serious lack of funding and lack of environmental law enforcement issues that cripple the effectiveness of the organization. (Not to mention the strong governmental and therefore corporate ties). The step from Superfund listing to Brownfields is a progressive attempt forward because it encourages and exemplifies the need for local activism and participation. The Brownfield program was intended to empower local communities and governments to apply for monetary awards so they may avoid third party interactions and revitalize the property however the community best sees fit. However, it is still tied to the EPA and subject to the political factors involved in site selections creating a program less and less different from the Superfund.
A study evaluating the impact of the EPA's community involvement programs documents that the EPA's "fundamental principle is that people who live and work near a site should know what EPA is doing to clean it up, and should have input into the cleanup decision-making process." However through the Fort Edward cause we can understand that public participation is heard only when it wants to be. Community members are quoted saying the EPA and GE made up their minds about the dewatering site location long before distributing any information to the people of Fort Edwards.
That same study found that there are several reasons why community members do not choose to participate in the Superfund decisions two of those being the " feeling incapable of providing knowledgeable input, and the belief that the EPA will do what it wants regardless of community input." EPA Participation Study
I would suggest a program with the same initiatives as the Brownfield organization yet the program must be disassociated from the EPA and handled entirely through local governments and public movements. Local-ism has the potential to make a drastic impact because it are those government officials, small business owners, and residents who are most affected and most importantly understand the complete extent of the hazardous site. Clean up decisions would be centered around choosing the best methods generating the most effective clean up with the least adverse health and local economic impacts.
References
EPA.Gov. Hudson River PCBs. Environmental Protection Agency. http://www.epa.gov/hudson/actions.htm
*Charnley, Susan and Bruce Engelbert. Evaluating Participation in Environmental decision-making: EPA's superfund community involvement program. Journal of Environmental Management. Volume 77, Issue 3, pages 165-182. November 2005. Science Direct. http://www.sciencedirect.com/science?_ob=ArticleURL&_udi=B6WJ7-4GXVGG8 2&_user=659639&_coverDate=11/30/2005&_rdoc=1&_fmt=high&_orig=search&_sort=d&_docanchor=&view=c&_acct=C000035878&_version=1&_urlVersion=0&_userid=659639&md5=33c70fe1d1b86f3e1cca626b1052c41f
*Dull, Matthew. Land Recycling, Community Revitalization, and Distributive Politics: An Analysis of EPA Brownfield's Program Support. Policy Studies Journal. Vol. 38 Issue 1 p119-141. 2010. http://search.ebscohost.com.libproxy.rpi.edu/login.aspx?direct=true&db=aph&AN=48368346&site=ehost-live .
Margiotta, Christine. "Dredging scope, specifics revealed." The Post Star. 24 Aug. 2005. Web.http://poststar.com/news/local/article_1304d566-da4b-5051-ac3d-93055ce2e7b0.html
Margiotta, Christine. “GE wants only one dewatering facility.” The Post Star. 23 June 2005. Web. http://poststar.com/news/local/article_62ef718f-af0a-5667-8123-9a7b0068d579.html
Stanclift, Gretta. “Dewatering Sites Opponents Speak.” The Post Star. Glens Falls, NY, 12 May. 2004. Web. http://poststar.com/news/local/article_075acef4-2636-57fe-afe0-310bbb2bdcb3.html
*O'Neil, Sandra. Superfund: Evaluating the Impact of Executive Order 12898. Environmental Health Perspectives; Jul2007, Vol. 115 Issue 7, p1087-1093, 7p, 2. EPSCOHost. http://search.ebscohost.com/login.aspx?direct=true&db=aph&AN=25812960&site=ehost-live]
Clinton WJ. 1994. Executive Order 12898. Federal actions to address environmental justice in minority populations and low-income populations Fed Reg59:FR7629 http://www.hud.gov/offices/fheo/FHLaws/EXO12898.cfm
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